Conduct Policies and Disclosures*
Public Pension Fund Reform Code of Conduct
Ares Management LLC ("Ares,"we," "us" or "our") became a signatory to the NYAG Public Pension Fund Reform Code of Conduct (the "Code") in February 2010. Pursuant to the Code, Ares is providing information regarding professional backgrounds of its Senior Management and other personnel whose standard professional duties include communicating with public pension fund investors and their officials, advisors, fiduciaries and employees ("Disclosure Persons"). The list of the Disclosure Persons can be found here.
In addition, Ares is providing details of certain political contributions. This campaign contribution information and other certifications related to the Code can be found by clicking here.
MiFID II Annual Best Execution Disclosure
In compliance with Article 27 of the recast Markets in Financial Instruments Directive ("MiFID II") and the corresponding Regulatory Technical Standard 28 of the delegation regulation, Ares Management Limited has published its annual best execution disclosure, setting out quantitative and qualitative information with respect to its approach to execution. Click here for the 2018 Annual Best Execution Disclosure, here for the 2019 disclosure and here for the 2020 disclosure.
UK Stewardship Code
The Financial Reporting Council has produced The UK Stewardship Code for institutional investors. It aims to enhance the quality of engagement between institutional investors and companies to help improve long-term returns to shareholders by setting out good practice on engagement with investee companies. Click here for the UK Stewardship Code Disclosure Statement.
Shareholder Rights Directive Disclosure (“SRD II”)
The Shareholder Rights Directive II (SRD II) is a European Union (EU) directive, which sets out to strengthen the position of shareholders. SRD II also establishes specific requirements to encourage shareholder engagement. Click here for the SRD II Disclosure Statement.
UK Modern Slavery Act 2015
In compliance with the UK Modern Slavery Act 2015, Ares Management Limited has published its annual Modern Slavery Act Statement, setting out the steps it has taken to endeavor to ensure that slavery and human trafficking are not taking place in its business and supply chains. Click here for the Modern Slavery Act Statement.
Financial Instruments and Exchange Act of Japan
With respect to Ares funds that are registered in Japan, Ares will provide to any member of the Japanese public a copy of such documents as are required to be made publicly available pursuant to Article 63 and Article 63-4 of the Financial Instruments and Exchange Act of Japan.
Please contact [email protected] to request such documents.
[email protected] までお問い合わせ下さい。
UK COVID-19 Risk Assessment
Pursuant to UK Regulations, Ares has developed a COVID-19 Risk Assessment in connection with our London office, which can be viewed here.
Sustainable Financial Disclosure Regulation ("SFDR")
The Sustainable Financial Disclosure Regulation (“SFDR”) is a European Union (EU) Regulation, which lays down harmonised rules for financial market participants and financial advisers on transparency with regard to the integration of sustainability risks and the consideration of adverse sustainability impacts in their processes and the provision of sustainability‐related information with respect to financial products.
Click here for Ares Management Luxembourg’s SFDR Statement.
*Ares Management UK Limited has a complaints policy and is covered by the Financial Ombudsman Service ("FOS") in respect of business conducted for and with eligible complainants. The FOS is a UK agency for arbitrating on complaints between regulated firms and their clients that meet the FCA definition of eligible complainant. Full FOS details can be found on its website at www.financial-ombudsman.org.uk